Pecorama Privacy Policy

Pritchard Patent Product Company (2001) Limited

GDPR Data Protection Policy

Introduction

As we engage with people interested in our services, we need to collect and use information that

relates to them.

We also need to collect and use information about the people who work with us, which includes

employees, suppliers, consultants, contractors and other people that we have a relationship with.

This policy describes how we will collect, handle and store people’s personal data to ensure that we

meet our high data protection standards and to show to people that we comply with relevant

legislation.

Why have we created this policy?

This policy ensures that Pritchard Patent Product Company (2001) Limited:

• Complies with data protection laws and follows good practice;

• Upholds the rights of its employees, customers and partners;

• Is fair and transparent in how it collects, processes and shares personal data; and

• Protects the individual personal data it holds, by reducing the likelihood of a data breach.

Data protection law

The General Data Protection Regulation (GDPR) sets out how organisations, including Pritchard

Patent Product Company (2001) Limited, must collect, process and share personal data. These rules

apply regardless of whether data is stored electronically, on paper, or using other

materials/methods such as CCTV or other recordings such as call recordings, drones and dash cams.

Personal data or Personally Identifiable Information (PII) as it is known under the GDPR, is

information that can be used on its own, or with other information to identify, contact, locate or

identify a living person. Information can include but is not limited to:

• Name

• Email address

• Telephone number

• Postal address

• Date of birth

You should assume that whenever you handle personal data, it will involve some type of processing

and therefore it must be carried out in accordance with the requirements of the GDPR. At least one

of the following must apply to permit you to collect and process personal data:

1. Legitimate Interests: the processing of personal data is necessary for the company’s

legitimate interests unless there is good reason to protect the individual’s personal data. The

test is whether an individual would, or should, reasonably expect the processing to take

place by the company

2. Contract: the processing is necessary for the performance of a contract with the individual,

or to take steps to enter into a contract e.g. contracts of employment, reservation

agreements

3. Legal Obligation: the processing is necessary for us to comply with the law (not including

contractual obligations) e.g. undertaking Anti-money laundering checks for fraud prevention

4. Vital Interests: the processing is necessary to protect someone’s life i.e. keeping next of kin

information for health and safety purposes

5. Consent: we have obtained the individual’s consent to process the personal data e.g. when

sending out marketing campaigns

 

Pritchard Patent Product Company (2001) Limited must be responsible for and be able to

demonstrate that personal data is:

1. Processed fairly and lawfully;

2. Obtained only for specific lawful purposes;

3. Adequate, relevant and not excessive;

4. Accurate and kept up-to-date;

5. Not held for any longer than necessary; and

6. Secure and protected.

 

People, Risks and Responsibilities

Who does this policy apply to?

• Pritchard Patent Product Company (2001) Limited Head Office;

• All brands of Pritchard Patent Product Company (2001) Limited;

• All divisions, branches and offices of Pritchard Patent Product Company (2001) Limited,

whether permanent or temporary;

• All employees, regardless of work level;

• All contractors, suppliers and other people working on behalf of Pritchard Patent Product

Company (2001) Limited;

• Any of our joint venture partnerships.

It applies to all personal data that the company holds, this includes:

• Customer information e.g. Prospects or those who have purchased our services, including

family members;

• Employee details e.g. Health information, financial details, benefits and pensions

• The use of CCTV within our Offices to ensure we provide a safe and secure environment for

all visitors to our premises and for the protection of our employees and property; and

• Recorded calls for training and quality purposes to and from our Customer Services and IT

Service desk.

What are the risks involved?

This policy helps to protect Pritchard Patent Product Company (2001) Limited from some very real

data security risks, including:

• Breaches of confidentialityThis could include information being given out inappropriately, sharing too much

information or sharing information without consent or lawful basis.

• Failing to be transparent

For instance, not telling individuals how their information will be used, using their

information for different reasons to what they have been told and failing to inform

individuals as to how they can exercise their rights.

• Reputation damage

For example, the company could suffer if hackers successfully gained access to sensitive data

or it was found to be breaching privacy principles.

• Fines

The company could be fined up to €20 million, or 4% of global turnover, whichever is higher.

Individuals could also bring a compensation claim against the company for any damages that

they believe they have suffered.

The ‘Data Protection Framework’

To ensure consistency in the way in which we handle personal data, Pritchard Patent Product

Company (2001) Limited has put in place a Data Protection Framework, which includes policies,

procedures, guidance and records.

It covers:

Our compliance processes and procedures

Employee awareness training ensures that teams are aware of data protection and its implications

before choosing a particular route. Further details can be located within the Data Protection Chapter

under the Pritchard Patent Product Company (2001) Limited Policies and Procedures Manual.

Privacy and Security by Design

Data protection is fundamental to our approach to any new business or initiative. As a result, we

have integrated security and data protection into our operational processes. This means certain

changes, risks and incidents trigger specific actions such as:

• Documenting our processing activity

• Data Protection Impact Assessments (DPIA); and

• Change Control

Privacy by Design

Privacy by Design is an approach to company initiatives, projects and IT system changes that

promotes consideration of privacy and data protection compliance from the start. Undertaking this

process will help us identify any potential problems from an early stage, considering risk and

ensuring we put adequate measures in place to safeguard individual’s personal data.

Data Privacy Impact Assessments (DPIA)

Data Processing Impact Assessments (DPIA) is a tool that we use to identify and reduce the privacy

risks of any new or revised projects. A DPIA helps us to consider what data protection risks may

occur if we undertake a particular project or partner with a new third-party supplier. The DPIA helps

us to work through specific questions, which can reduce the risk of harm to individuals through the

misuse of their personal information. It can also help us design more efficient and effective

processes for handling personal data.Change Control

If you are looking to:

• introduce a new internal system; or

• make changes to existing systems and processes; or

• share data with new partners

then these must be assessed and be approved via the following Change Control Boards:

• Data Protection Officer (DPO)

o The DPO is the first tier responsible for taking a detailed holistic review of IT related

changes. Primary objectives of the DPO are to review, in detail, company IT

proposals and make recommendations to the Senior Management team as to

whether projects should be initiated and implemented into the company.

• The Directors approve changes and investment in new systems and allocates resource to IT

projects.

Governance

All employees should be aware of the structures in place, so that they can assure suppliers, identify

risks, report breaches in security and handle requests for information.

Responsibilities

Everyone who works for or with Pritchard Patent Product Company (2001) Limited shares the

responsibility of ensuring that data is collected, stored, processed and shared appropriately.

Departments or functions that handle personal data must process it in line with this policy and the

data protection principles. In addition to this, certain people and teams have specific areas of

responsibility:

• The Board of Directors

Ultimately responsible for ensuring that Pritchard Patent Product Company (2001) Limited

meets its legal obligations.

• The Data Protection Officer (DPO)

The person in this role is responsible for:

o Keeping the Board updated about data protection responsibilities, risks and issues;

o Reviewing all data protection procedures and related policies in line with an agreed

schedule to ensure they remain up to date and effective;

o Dealing with requests from individuals who want to see the data that Pritchard

Patent Product Company (2001) Limited holds about them (Subject Access

Requests);

o Has responsibility to reporting any breaches to the ICO;

o Handling data protection questions from employees and anyone else covered by this

policy;

o Checking and approving any contracts or agreements with 3rd parties that may

handle personal data; and

o Reviewing and signing-off Data Protection Impact Assessments.

• Group IT

They are responsible for:o Ensuring that all systems, services and equipment used for storing personal data

meet acceptable security standards;

o Performing regular checks and scans to ensure security hardware and software is

secure and fit for purpose; and

o Evaluating any 3rd party services the company is considering for the storage or

processing of personal data.

• Group Sales and Marketing

They are responsible for:

o Approving any data protection statements in our customer communications, such as

emails, letters and online;

o Where necessary, working with other employees to ensure marketing initiatives

abide by the data protection principles; and

o Ensuring marketing databases are checked against our suppression files (email

addresses not to be used by us) each time a marketing campaign is run.

• HR

They are responsible for:

o Ensuring the company holds employee data securely;

o Obtaining consent for any sensitive categories of data the company wishes to use;

o Has adequate measures in place between us and any external 3rd parties which

process personal data on behalf of the company (e.g. pension providers); and

o Arranging data protection training and awareness for the company.

• Management at all levels

These individuals are at Department and functional level and are responsible for:

o Ensuring fulfilment of the data protection provisions within their department or

function;

o Liaising with the Senior Management Team and DPO on responsibilities and

controls;

o Carry our local data destructions (paper stores etc);

o Complete a Self-Audit each year on behalf of the division on active GDPR controls;

and

o Assist the division in ensuring that DPIAs are considered and carried out.

• Senior Responsible Owner (SROs)

These are individuals who are responsible for:

o Introducing new systems; and

o Vetting our suppliers with whom we share personal data with.

General employee’s guidelines

To ensure the objectives of this policy are met, we have outlined the steps we should take as a

business to reduce the likelihood of a breach of information.

Necessary eyes only

The data covered by this policy should only be accessed by those who need to do so for work

purposes. Data should never be shared informally. Personal data should not be disclosed to

unauthorised people, either within the company or externally. Time to train

Pritchard Patent Product Company (2001) Limited will provide training to all employees, so that you

know what your responsibilities are when handling data.

Strong passwords

We must use strong passwords at all times and they should never be shared unless authorised by IT.

Our baseline standard criteria for passwords should:

• Not contain your username or full name, or parts of your username or full name that

exceed two consecutive characters;

• Be a minimum of 6 characters in length. There is no maximum length; and

• Contain a minimum of 1 character from three of the following four categories:

1. English uppercase characters (A-Z)

2. English lowercase characters (a-z)

3. Base 10 digits (0-9)

4. Non-alphabetic characters (e.g.!, £, #, %)

Ask for help

If you are unsure about any aspect of data protection, ask for help from your Line Manager or the

DPO.

 

Data storage

The following rules describe how and where data should be safely stored:

When keeping paper records:

• Keep data locked away: When not required, paper files should be kept in a locked drawer or

filing cabinet.

• Keep it secure: Paper and printouts must not be left where unauthorised people could see

them (e.g. on a printer).

• Shred when done: Any printouts of personal data should be shredded and disposed of

securely when no longer required.

When keeping electronic records:

• Use strong passwords: Data must be protected by strong passwords, see above, that are

never shared.

• Keep data locked away: If data is stored on removable media (e.g. USB, DVD) these must be

encrypted and kept locked away when not being used.

• Use designated servers: Data should only be stored on designated drives and servers and

should only be uploaded to approved cloud computing services.

• Use secure locations: Servers containing personal data must be sited in a secure location,

away from the general office space.

• Back-up frequently. Data backups must be tested in line with company standard backup

procedures.

• Keep it secure: Never save data directly onto your laptop or other mobile devices.

 

When using data:

• Secure your screen: When working with personal data, ensure that you always lock the

screen of your computer when unattended.• Keep it to yourself: Personal data should not be shared informally. Care should be taken

when sending emails which contain information that may harm an individual’s right to

privacy if disclosed to the wrong people – email is not a secure form communication.

• Use encryption: Data must be encrypted before it is transferred electronically.

• Ask before sending: Personal data should never be transferred outside the European Union

without consulting the Data Protection Officer or a senior Director.

• Keep it secure: Never save copies of personal data to your own computer.

• External storage solutions: Any personal data must not be stored onto external storage

solutions which are not managed by IT (i.e. personal Dropbox)

GDPR Data Map

To comply with the GDPR requirements, we will maintain a formal and accurate record of our data

processing activities. The Data Map is will include:

• Information assets;

• Processing & activities;

• 3rd Parties (Partners);

• Data Transfers; and

• Risks and Controls.

Data accuracy

It is important that the data we process is accurate and, where necessary, kept up-to-date. In fact,

the more important the information is, the greater the effort we should put into ensuring its

accuracy.

Storing data

Data should be held in as few places as necessary. Employees should not create any unnecessary

additional data sets.

Correcting data

Employees should take every opportunity to ensure data is up-to-date, for instance, by confirming a

customer’s details when they call. Be sure to update our systems as soon as you discover an

inaccuracy.

Enabling amends

Pritchard Patent Product Company (2001) Limited make it easy for individuals to update the

information held about them (e.g. via notification to HR and Payroll).

Requests for information

If individuals contact us to ask about the information we hold on them, it is called a ‘subject access

request’. All individuals that we hold information about are entitled to:

• Request to know what information Pritchard Patent Product Company (2001) Limited holds

about them and why;

• Ask for a copy of the information we hold about them;

• Learn how to keep their data up-to-date;

• Learn how to object to processing;

• Find out how their data is being used; and• Learn about the security safeguards we have in place to prevent the accidental or deliberate disclosure of their information.

Subject access requests are addressed in a separate policy.

Disclosing data for legal reasons

In certain circumstances, the GDPR requires personal data to be disclosed to law enforcement

agencies without the consent of the individual concerned.

Under these circumstances, Pritchard Patent Product Company (2001) Limited will disclose the

requested data. However, the Data Protection Officer must be informed first, so that they can

confirm the request is legitimate and ensure that it is handled correctly.

In the interest of fairness

It’s our aim to make sure that individuals understand when their data is being processed, how their

data is being used and how to exercise their rights. To achieve this, we have written a GDPR Data

Protection Policy and Cookies Policy, which sets out how personal data is used by the company(s).

This is available on the Pritchard Patent Product Company (2001) Limited website.

DigiTickets Privacy Policy

Policy Owner

This policy is owned and distributed by IT and Compliance manager of Digital Ticketing Systems Limited

Who we are

In this Privacy Policy, references to "we", "us", and "our"" are to Digital Ticketing Systems Limited (Company number 07044584). References to "our Website" or "the Website" are to *.digitickets.co.uk.

Digital Ticketing Systems Limited is the data controller responsible for the personal information collected through this Website.

Information We Collect

We may collect and process the following categories of personal information:

Information You Provide Directly

When you contact us, make a purchase, register for services, or complete forms on our Website, we may collect information such as:

• Name
• Postal address
• Email address
• Telephone number
• Purchase and booking information
• Any other information voluntarily provided by you

Payment Information

Payments made through our Website are processed by authorised payment service providers. We do not store your full credit or debit card details on our systems.

Our payment providers may process payment information and carry out fraud prevention and verification checks. Where international transfers are required, appropriate safeguards will be applied in accordance with applicable data protection laws.

Digital Ticketing Systems is PCI DSS v4.0.1 compliant and are annually assessed/certified.

Website Usage Information

When you visit our Website, we may automatically collect:

• IP address
• Browser type and version
• Device information
• Screen resolution
• Operating system
• Referral source
• Pages visited and actions taken on the Website
• Date and time of access

Marketing Preferences

If you choose to receive marketing communications, we will record your preferences and any interactions with our emails, including whether emails are opened or links are clicked.

Cookies and Similar Technologies

We use cookies and similar technologies to operate our Website, remember your preferences, analyse usage, and improve user experience. Further information is provided in our Cookie Policy below.

How We Use Your Information

We process personal information for the following purposes:

• To provide products and services you request
• To process transactions and fulfil orders
• To provide customer support and after-sales services
• To manage bookings and accounts
• To improve our Website, products, and services
• To ensure Website security and prevent fraud
• To comply with legal and regulatory obligations
• To send marketing communications where we have your consent or another lawful basis to do so

Lawful Basis for Processing

Under UK GDPR, we rely on one or more of the following lawful bases:

• Performance of a contract: to provide goods or services you have requested.
• Legal obligation: where processing is necessary to comply with legal requirements.
• Legitimate interests: to manage and improve our business, Website security, and customer experience.
• Consent: where required, including for certain cookies and marketing communications.

Where we rely on consent, you may withdraw it at any time.

Sharing Your Information

We may share your personal information with:

• Payment processors
• Hosting and IT service providers
• Delivery and fulfilment partners
• Marketing and communications providers
• Analytics and Website performance providers
• Professional advisers and auditors
• Regulatory authorities, law enforcement agencies, or courts where required by law

All third-party service providers are required to process personal information only on our instructions and in accordance with applicable data protection laws.

We do not sell personal information to third parties.

International Transfers

Where personal information is transferred outside the United Kingdom, we will ensure appropriate safeguards are in place, such as:

• Transfers to countries deemed to provide an adequate level of protection; or
• Approved contractual safeguards, such as the UK International Data Transfer Agreement (IDTA) or equivalent mechanisms.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, regulatory, and reporting requirements.

Retention periods vary depending on the type of information and the purpose for which it is processed.

Cookie Policy

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites function properly, remember preferences, improve performance, and provide analytics information.

How We Use Cookies

We use the following categories of cookies:

Strictly Necessary Cookies

These cookies are essential for the operation of the Website and cannot be disabled through our cookie management tools.

Cookie	Purpose	Duration
PHPSESSID	Maintains user session and shopping basket functionality	Session / 24 minutes
dtAnalyticsConsent	Records cookie consent preferences	1 year

Analytics Cookies

These cookies help us understand how visitors interact with the Website so that we can improve performance and usability.

These cookies are only placed with your consent.

Google Analytics

Examples include:

• _ga
• _ga<container-id>
• _gid
• _gat_<tracker-name>

Used to collect aggregated statistical information about Website usage.

Google Privacy Information:

https://support.google.com/analytics/answer/6004245

Microsoft Clarity

Examples include:

• _clck
• _clsk
• CLID
• ANONCHK
• MR
• MUID
• SM

Used to analyse user interactions and improve Website usability.

Microsoft Clarity Information:

• https://clarity.microsoft.com/blog/cookies-in-clarity/
• https://learn.microsoft.com/en-us/clarity/

Performance Monitoring Cookies

Performance monitoring tools help us identify technical issues and improve Website reliability.

Examples may include cookies used by services such as New Relic.

Managing Cookies

When you first visit our Website, you will be presented with a cookie banner allowing you to:

• Accept all cookies
• Reject non-essential cookies
• Choose your cookie preferences

You may change your preferences at any time through our cookie settings tool.

You can also manage cookies through your browser settings. Disabling certain cookies may affect Website functionality.

Your Data Protection Rights

Under UK GDPR, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your information
• Restrict processing
• Object to processing
• Request portability of your data
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Information Commissioner's Office (ICO)

For more information about your rights, visit:

https://ico.org.uk/

Automated Decision-Making

We do not generally make decisions producing legal or similarly significant effects using solely automated processing.

Where automated tools are used for fraud prevention, security monitoring, or service administration, appropriate safeguards will be applied in accordance with applicable data protection legislation.

Childrens Data

Our Website is not intended to knowingly collect personal information from children unless necessary to provide services requested by a parent, guardian, school, attraction, venue, or authorised organisation.

Where we process children's personal information, we take additional care to ensure appropriate protections are in place.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact:

Digital Ticketing Systems (t/a DigiTickets)

Sentio House, Pynes Hill, Exeter, Devon, EX2 5AZ

www.digitickets.co.uk/compliance-request

If you have concerns about how we use your personal information, you may submit a privacy complaint to us using the contact details above.

We will acknowledge your complaint and investigate it in accordance with applicable data protection legislation. We aim to respond without undue delay and within the timescales required by law.

If you remain dissatisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO).

Other Websites

This Privacy Policy applies only to this Website. Links to third-party websites are provided for convenience only. We are not responsible for the privacy practices of those websites, and we encourage you to review their privacy policies before providing any personal information.

Last Updated: 5 August 2026